Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Rebate claim - Relevant Date - The period of limitation of one year commences from the Relevant Date. The relevant date as defined in Explanation (B) to this provision, states that for the purposes of goods exported by sea, is the date on which ship in which goods are loaded, leaves India. Thereafter the relevant date for other contingencies has been enumerated and Clause (f), the residuary clause states that in any other case, the relevant date will be the date of payment of duty. - HC
Rebate claim - Relevant Date - The period of limitation of one year commences from the Relevant Date. The relevant date as defined in Explanation (B) to this provision, states that for the purposes of goods exported by sea, is the date on which ship in which goods are loaded, leaves India. Thereafter the relevant date for other contingencies has been enumerated and Clause (f), the residuary clause states that in any other case, the relevant date will be the date of payment of duty. - HC
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